Anti-Bribery Policy

Company Letterhead

{{company_name}}

{{company_address}}

Phone: {{phone}}

Email: {{email}}

Website: {{website}}

1. Introduction and Policy Statement

{{company_name}} is committed to conducting its business ethically and with integrity. This Anti-Bribery Policy ("the Policy") outlines our zero-tolerance approach to bribery and corruption and applies to all employees, directors, officers, agents, contractors, and any other persons associated with our business operations, wherever they are located. We are committed to upholding all anti-bribery and anti-corruption laws, including but not limited to, the Prevention and Combating of Corrupt Activities Act (PRECCA) in South Africa, and other relevant international legislation.

Any breach of this Policy will be treated as a serious disciplinary matter, potentially leading to dismissal and/or criminal prosecution.

2. Scope of the Policy

This Policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, volunteers, interns, agents, or any other person associated with us (collectively referred to as "Associated Persons").

This Policy covers all business dealings and transactions in all countries where {{company_name}} operates.

3. What is Bribery?

A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial, contractual, regulatory, or personal advantage. Bribery can take many forms, including but not limited to:

a. Offering, promising, or giving a financial or other advantage directly or indirectly to another person with the intention of inducing or rewarding them to perform improperly a relevant function or activity.

b. Requesting, agreeing to receive, or accepting a financial or other advantage directly or indirectly in exchange for improperly performing a relevant function or activity.

c. Offering or giving something of value to a foreign public official with the intention of influencing them in their official capacity and obtaining or retaining business or an advantage in the conduct of business.

4. Gifts, Hospitality, and Expenses

Associated Persons must not offer, give, solicit, or accept gifts or hospitality to or from third parties if it is intended to improperly influence a business decision or create a sense of obligation. All gifts and hospitality must be reasonable, proportionate, and have a legitimate business purpose.

a. Gifts: Modest, unsolicited gifts of nominal value (e.g., promotional items) may be accepted. Any gift valued over {{threshold_gift_value}} must be declared to {{compliance_officer_position}} and recorded in the {{gift_register_name}}.

b. Hospitality: Reasonable and proportionate hospitality (e.g., business meals or tickets to events) may be accepted or offered as part of customary business courtesies, provided it is not frequent or excessive. All hospitality exceeding {{threshold_hospitality_value}} per instance must be approved by {{approving_manager_position}} and recorded.

c. Expenses: All business expenses must be legitimate, reasonable, and incurred in the ordinary course of business. Falsification of expense claims is strictly prohibited.

5. Facilitation Payments

Facilitation payments are small, unofficial payments made to secure or expedite a routine or necessary action to which the payer is legally entitled (e.g., speeding up customs clearance). {{company_name}} has a strict zero-tolerance policy towards facilitation payments, as they are considered bribes and are illegal in most jurisdictions. Associated Persons must not make or accept facilitation payments. Any requests for such payments must be reported immediately to {{compliance_officer_position}}.

6. Charitable Donations and Sponsorships

Charitable donations and sponsorships are permitted and encouraged, provided they are made in accordance with applicable laws, ethical standards, and {{company_name}}'s internal policies. They must not be used as a disguise for bribery. All donations and sponsorships exceeding {{threshold_donation_value}} must be approved by {{approving_manager_position}} and recorded, ensuring due diligence is conducted on the recipient organization.

7. Reporting Suspicions and Concerns

Associated Persons have a responsibility to report any actual or suspected instances of bribery or corruption without fear of retaliation. All concerns should be reported to {{reporting_channel_contact}} or {{alternative_reporting_channel_contact}}.

Reports will be treated confidentially, and no Associated Person will suffer any detrimental treatment as a result of reporting a genuine concern in good faith, even if it is later found to be mistaken.

8. Training and Awareness

{{company_name}} will provide regular training to ensure that all Associated Persons understand their obligations under this Policy and relevant anti-bribery laws. All Associated Persons are required to complete this training as directed.

9. Monitoring and Review

This Policy will be reviewed regularly, at least annually, by {{reviewing_body_or_position}} to ensure its continued effectiveness and compliance with applicable laws. Any necessary amendments will be communicated to all Associated Persons.

Signatures

Policy Approved By:

_____________________________

Name: {{approver_name}}

Title: {{approver_title}}

Date: {{approval_date}}

Acknowledged By:

_____________________________

Employee Name: {{employee_name}}

Employee Signature: _____________________________

Date: {{acknowledgement_date}}